Animal testing back in the news

By Siouxsie Wiles 03/12/2012

The press seems to be full of people frothing at the mouth over suggestions by Associate Health Minister Peter Dunne that the manufacturers of ‘legal highs’ should be required to provide safety information on their products before they are allowed on New Zealand shelves. This comes on the back of the minister announcing a Temporary Class Drug Notice banning a substance called EAM-2201 found in samples of a synthetic cannabis product. EAM-2201 appears to be a synthetic hybrid of two known cannabinoid compounds previously used as active ingredients in synthetic cannabis blends, but which are now banned in many countries.

What has really got people upset is the suggestion that dogs and rats will be force feed ‘legal highs’ until half of them die (the so-called LD50 assay [the lethal dose at which 50% of animals are killed]) in an effort to provide us with some information on their ‘safety’. There is lots of talk of this test being banned in the UK. It’s certainly banned for the use of cosmetic testing in Europe but I’m not sure about all chemicals.

Four things strike me about this story:

1. Are the majority of people aware that there are products for sale which have essentially never been tested on humans or animals?

2. That people who take ‘legal highs’ are probably taking them because they are a legal alternative to illegal drugs. Ironically, we know an awful lot about illegal drugs so they are probably the safer alternative. It is also ironic that it is perfectly legal to buy tobacco and alcohol, two extremely harmful ‘drugs’.

3. That Peter Dunne and almost everyone else who commented on the story* has no idea how animal testing is regulated in New Zealand. This is what I want to comment on a little later.

4. What does everyone mean by ‘safety’ in reference to these ‘legal highs’? Do they mean LD50 (presumably we would want to know the dose likely to kill people rather than rats and dogs)? Or do they want to know if they are addictive? There was mention in the original press release banning EAM-2201 of its use being tied to “elevated heart rate, vomiting, anxiety and psychosis”. So is it anxiety and psychosis we are interested in? These are important questions, as they will determine the kinds of tests that need to be performed.

In New Zealand we have the Animal Welfare Act 1999 which came into force on the 1st January 2000. There is information about the Act on the Ministry for Primary Industry’s website here. Part 6 of the Act relates to the use of animals in research, teaching and teaching. It sets out that:

1. No research, testing or teaching may be carried out on any live animal unless the person or organisation involved holds an approved code of ethical conduct.

2. No project may proceed without the approval of an animal ethics committee (AEC) established under such codes.

3. The AEC comprises 3 members from outside the organisation holding the code of ethical conduct.

4. The AEC is subject to independent review.

5. The AEC will only approve research if there is a proven benefit and if that benefit outweighs the cost to the animals used.

6. The AEC will promote the use of the 3 Rs: replacement of animals with a non-living or non-sentient alternatives, reduction of numbers to the minimum required, and refinement of techniques to minimise harm and suffering.

So let’s get one thing clear. It is highly unlikely any ethics committee would approve LD50 tests for party pills in New Zealand. I should know because I’m a member of one. So should these untested products be on our shelves? And if they are to be tested, what are the criteria? It’s a tricky one. Personally I’d like to see how they do on the spider web test!

From Noever, R., J. Cronise, and R. A. Relwani. 1995. Using spider-web patterns to determine toxicity. NASA Tech Briefs 19(4):82. Published in New Scientist magazine, 29 April 1995.

*With the exception of Virginia Williams, the chair of the National Animals Ethics Advisory Committee (NAEAC) who appears to be the lone voice of reason.

0 Responses to “Animal testing back in the news”

  • I get slightly worried by people who seem to prefer to have the illegal drugs tested on teenagers.

  • I can’t help suspecting this is part of some anti-drug crusade by Peter Dunne; if he spins it right, he could look like the dog-lover who refused to bow to the nasty scientists, and could get party pills banned as a bonus. The Herald ran a whole story yesterday about LD50 testing without mentioning that these tests haven’t actually been planned or even proposed. Facebook and Stuff comments are going ballistic. And of course the losers are scientists: thousands of people now believe that killing dogs is a routine part of medical testing in New Zealand. Brilliant.

  • I overheard someone say that Dunne is considering testing LD50 in dogs to make the banning of legal highs more palatable for the uninformed masses – the streets of auckland are filled with, uh, interesting, people.

  • Does the benefit of knowledge of a drugs specific toxicities (which will likely be widely used in uncontrolled settings) outweigh the cost to the animals used?

    It seems to me the if the benefit is human safety, then the cost could be potentially justified.

    It also seems that many think that the benefit of the testing here is people being able to get high. I submit this is not the case. The benefit is the reduction in risk and harm – which without the testing is potentially quite large.

  • Siouxsie, why are you quoted by Stuff as saying there is no need to test chemicals on animals? You are a microbiologist, and you are not trained in toxicology. As a double-Board-certified toxicologist who has worked for years in preclinical drug testing, I can state that the information you gave to Stuff is absolutely wrong and misleading, but I wonder why on earth a microbiologist is presuming to talk to the news media about a field she clearly knows nothing about, anyway. In vitro cell toxicity testing cannot and does not replicate the complexity of the living animal. Many substances that are completely innocuous in the living body are toxic in cell culture.
    There is no need to perform an LD50 test on party pills but adequate toxicity testing will require animal testing, which can be conducted at dose levels that do not cause suffering.
    The spider web test is not a recognized test for neurological effects of chemicals in mammals, for obvious reasons.
    I am absolutely appalled that you would presume to talk the news media about toxicology when you have zero training in toxicology. I would not presume to talk to the news media about microbiology!

    • Hi Rosalind

      Thanks for your message and I can understand your frustration. Firstly, I am not quoted as saying there is no need to test chemicals in animals. My quote in fact is “there are lots of things you can do to see if a compound is dangerous before you get it into an animal”. I stand by that statement which somehow became the headline ‘No reason party pills have to be tested on animals’.

      I was approached by a journalist from the Sunday Start Times because of writing this blog post. I immediately referred him to Virginia Williams, NAEAC’s chair but he just asked for some info on the 3Rs and how likely I thought it would be that dogs would be used. As with any article, the quotes they have used do not reflect the whole conversation. I made it clear I thought rodents were more likely to be used than dogs. In fact, what I was trying to get across to the journalist was that there were unlikely to be rooms full of dogs dying as part of an LD50 test, which is the image that seems to be in everyone’s minds. Instead I talked to him about humane endpoints, and minimising suffering as you describe. Unfortunately he didn’t report that.

      From my blog post you can see that what I was commenting on was how animal use is regulated in NZ and why some company couldn’t just go off and do tests on animals. I was also trying to raise the point that the use of animals was dependent on the question being asked. The journalist asked me about this which is why I said there were plenty of things that were done BEFORE a chemical ever got into an animal, like looking to see if it was carcinogenic using bacteria. The mention of the ‘spider web test’ in my post was meant as an amusing aside. Do you seriously think I was advocating its use as “a recognized test for neurological effects of chemicals in mammals”?!

      I am sorry that you are upset that a microbiologist had the nerve to step up and talk about the use of animals in toxicity testing. My intention was purely to explain that animals are used humanely and only when necessary. Alas, the headline does not reflect my position but I believe this is a common thing in media!

      Please do write in and explain to them how toxicity testing is done. As you say, you are much better qualified than me to do so and it would be great to get some more info on the humane way these things are done out there.

  • I should add that I do have two years’ tertiary training in microbiology, but I still would not consider it appropriate to talk to the news media, but would refer them to someone with real expertise in the field. Why didn’t you refer the enquiry to a toxicologist? There are two Board-certified mammalian toxicologists in New Zealand, myself and Dr. Rhian Cope. Either of us could have given accurate information, but you clearly could not.

  • Also, just because you think it is a ‘tricky’ question as to how neurological effects should be assessed in nonhuman subjects, does not mean that it is ‘tricky’. In fact there are a substantial number of very well validated neurological assays available to toxicologists for use in nonhuman species. Just because you don’t know what they are, does not mean nobody knows! I certainly do, and I’m sure Dr Cope does too.

  • Rosalind,

    You are assuming that Stuf correctly quoted/understood what Siouxsie said to them. You might be aware that it is not uncommon for the media to misquote/simplify/misinterpret what a scientist has said to them.
    Siouxsie has done some fascinating work to minimise the use of animals in research, research that she has received some recognition for, and something the media is interested in.
    If you have something you think the media is interested in, have you ever considered talking with them? A warning though, it may not be as easy as you might think.

  • I have emailed the editor of, made a comment on their facebook page, and have commented on a number of Stuff articles. I have not had a reply from the editor, and my comments on their website don’t show up. They are absolutely not interested to hear from someone who actually knows what they are talking about, even though I probably have more experience in GLP animal toxicity testing, to meet the requirements of the USFDA, MHLW and OECD, than anyone else in New Zealand. You fell for their determination to get a uninformed opinion and misrepresent it as an informed one.

    LD50 studies are rarely required but I have done them, and have in fact commissioned and supervised no less than three LD50 studies in rats at a NZ university in the last 3 years, so your claim that no NZ animal ethics committee would approve them is factually wrong. We had no choice but to use the OECD Guideline 425 because we needed to assess the acute toxicity of certain toxins that contaminate human food, relative to similar compounds for which only LD50 values exist. Each LD50 study took only about 8 rats and most of them were terminated rather than being found dead. Also, while in the US, I conducted classical LD50 studies to assess the potency of isolates of Botulinum toxins A, B and E. Each study used 28 guinea pigs (7 groups of 4). This is the standard way to measure potency of a preparation of Botulinum toxin, and therefore provides the only meaningful assay. Again, I was very proud of my technicians because very few of the guinea pigs were found dead. Most that died were terminated humanely when it became clear that they were so severely affected that they would not recover.

    I do think it is ridiculous for a microbiologist to comment on toxicology, just as it would be ridiculous for me to offer a supposedly ‘informed opinion’ on, say, botany or astronomy. I have the humility to know the limits of my expertise.

    • Rosalind,

      You say my “claim that no NZ animal ethics committee would approve them [LD50 tests] is factually wrong” because you have run such tests in NZ “to assess the acute toxicity of certain toxins that contaminate human food”.

      What I actually said was “It is highly unlikely any ethics committee would approve LD50 tests for party pills in New Zealand”. Again I stand by this statement as I don’t think the benefit of doing the experiments would outweigh the cost to the animals.

      Please stop deliberately misquoting me.

  • Rosalind,

    You wrote: ‘I have not had a reply from the editor, and my comments on their website don’t show up.’

    From what others have suggested to me, editors rarely reply to criticism. It may, in part, simply be the volume of correspondence they get. (In some cases there may be more at play, but that’s the relevant bit here.)

    The newspaper websites are slow to approve comments, unlike here at sciblogs. I’d wait until tomorrow midday (say) before thinking they haven’t accepted your comment.

    You wrote: ‘You fell for their determination to get a uninformed opinion and misrepresent it as an informed one.’

    Another possibility is that the journalist couldn’t get a hold of Williams as Siouxsie and had to run with what he had — journalists work under tight time limits, which can lead to less-than-ideal outcomes.

    FWIW there are probably many people in the country that could outline the basics – perhaps most people who had have close involvement with a research ethics committee, for example.

    Regards your final paragraph I personally am cautious about resting things on labels as in my experience people’s particular backgrounds matter too (what projects they’ve done, what committees they’ve been involved in, etc). In the interest of not stirring passions, I’ll refrain from elaborating with examples!

  • Siouxsie, I didn’t deliberately misquote you, it was accidental. I did not check your precise wording and that was my error. It seems a little mean-spirited of you to assume it was deliberate.

    If a scientific case could be made that an LD50 test is the only way to go for party pills, as can be made for a variety of toxins from various organisms, then an Animal Ethics Committee should approve the test, notwithstanding the preconceived notions of any members with no expertise in toxicology. Animal Ethics Committee members should be open-minded and ready to consider the argument/s for the test. Without a thorough review of the diverse chemical nature of party pills, it is premature to say that an LD50 test would not be required.

    Grant, I don’t agree that there are many people in New Zealand who could outline the basics of toxicology testing, because I know for a fact that there are very few of them. I do agree about your caution at resting things on labels, because there are quite a few people in this country who call themselves toxicologists but clearly know very little about toxicology. My years in preclinical safety testing for pharmaceuticals contributes more to my expertise in designing suites of toxicity tests than my Boards do, and there are almost certainly DABTs out there who would do a poor job of putting together such suites because they would have to work from a textbook rather than from personal experience.

  • As another comment, I’m not sure why the safety testing for party pills would be done in New Zealand. There are numerous contract labs that would do the testing more efficiently and with greater technical expertise in the US, China and India, and those in China and India, in particular, are cost-competitive with the home-grown article and much more experienced.

  • Rosalind, You must know that ‘because there are quite a few people in this country who call themselves toxicologists but clearly know very little about toxicology’ was not my point. (It’s not polite to turn other’s words around to different meanings.)

  • Hi, Im reading this page as purely an animal lover. and I m stunned that any one should even think of testing these crazy drugs on animals, why on earth anyone this garbage to party is beyond me, let alone force -feed it to some unfortunate animal .
    Any substance that alters anybody,s mental state is dangerous, where does ACC stand on this issue, after all they currently pick up the tab for the collateral damage.
    never mind testing the animals, ban the drugs.